Mainsail Ltd Privacy Notice

This Privacy Notice applies to personal data processing under MAiNSAiL Ltd and/or any of the following brands within MAiNSAiL Ltd. Each ‘brand’ may have a supplemental privacy notice which provides additional information regarding brand specific personal data processing and is provided at the point of data collection and should be read in conjunction with this Mainsail Ltd Privacy Notice. Brands include:

• The Hive Network
• RetailJam
• CMX

MAiNSAiL Ltd (herein ‘we’ or ‘us’ or ‘our’) gather and process personal information in accordance with this privacy notice, and any supplemental privacy notices, and in compliance with the relevant United Kingdom data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why, and when we process your personal data.

MAiNSAiL Ltd’s registered office is at 52 High Street, Pinner, Middlesex, HA5 5PW and we are a company registered in England and Wales under company number 09545849. We are registered on the Information Commissioner’s Office Register; registration number ZB304956, and act as the data controller when processing your personal data. We have an Appointed Person, Lydia Matthews, with responsibility for the oversight and of, and compliance with, data protection law, and they can be contacted by post at The Hive Network, Warnford Court, 29 Throgmorton Street, London, EC2N 2AT, or via email using dataprivacy@thehive-network.com, or by phone using +44 (0) 20 3948 1623 and asking for Lydia Matthews, our Appointed Person.

Information that we collect

We process your personal information to meet our legal, statutory, and contractual obligations, and to provide you with our products and services, or when you are applying to us about employment. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice or a brand specific supplementary notice.

The personal data that we may collect and process, include and may not be limited to:

• Name, gender (should you choose to give it), birth dates, etc.
• Personal identifiers, e.g., National Insurance number, work IDs, etc.
• Home address and personal contact information, phone, email, etc.
• Business contact and email details, phone, email, etc.

We collect information in the following ways:

Via online enquiry forms on our website, via emailed enquiries, career applications, general correspondence, via telephone enquiries, and via use of our Apps, etc.

How we use your personal data

We take your data privacy very seriously and will never disclose, share, or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.  The purposes and reasons for processing your personal data are detailed below:

• We collect and store your personal data when responding to your enquiry via our website, through social media, applications, the telephone or in person.
• We collect and store your personal data in providing our products and/or services and when responding to enquiries relating to these.
  • This includes processing your personal data within any App to which you will have subscribed and use.
  • This may include processing personal data within the App in communications between other members of that App.
• We collect and store your personal data a part of fulfilling a contract with you as a contractor working with us or as an employee of the company.
• We collect and store your personal data as part of our legal obligation for business accounting and taxation purposes.
• We may occasionally send you marketing information where we have assessed that it is beneficial to you as a client and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.

Your Rights

You have the right to access any personal information that we process about you and to request information about:

• What personal data we hold about you.
• The purposes of the processing.
• The categories of personal data concerned.
• The recipients to whom the personal data has/will be disclosed.
• How long we intend to store your personal data for.
• Where we did not collect the data directly from you, information about the source of that data.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent other than for the purposes specified in this notice or where there is a legal requirement. We use some third parties to provide the services to our business functions that enable us to deliver our services to you.

All third-party processors acting on our behalf only process or access your data in accordance with instructions from us and comply fully with this privacy notice, data protection laws and any other appropriate confidentiality and security measures.

These third parties may include our legal and accountancy professionals, our network and infrastructure support providers, and our contractors supporting our App and web programming and where these parties are required to access personal data, they will do so under a legal contract or an agreement known as a Data Protection Agreement, depending upon their status.

When using one of our Apps, as an example: The Hive Network, others who you have permitted to connect with you, may see some or all of your personal data and how much they see, is controlled by you within your profile settings.

Safeguarding Measures

We take your data privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and have several layers of information security measures in place, including but not limited to:

• SSL, TLS, encryptions, pseudonymisation, restricted access, network authentication, firewalls, anti-virus/malware etc.
• Data is encrypted at rest and in transit.

Transfers outside the United Kingdom

Personal data of United Kingdom data subjects is protected by the United Kingdom General Data Protection Regulation (UK GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.

We do not process personal data outside of the United Kingdom and our application servers are located in the United Kingdom.

International users and subscribers to of any of our Apps, may be able to see information relating to another user and that data visibility, is controlled by the users directly. Users choose what to share with others.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to us however, as this information is required for us to provide you with our products/services or respond to your enquiries, we will not be able to offer some or all our products/services without it.

How Long we Keep your Data

We only retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. As an example, we are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years plus the current year, after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Your personal data within the Apps, is retained until such time as you choose to close your account and/or delete your data. It is possible that some limited personal data may be retained after your close your account on an App for a limited period, where required under a specific lawful basis such as, fulfilling a legal obligation, and this will be retained for no longer than is required for that purpose.

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO).

To contact MAiNSAiL Ltd

• Data Protection Appointed Person: Lydia Matthews
• Postal contact: The Hive Network, Warnford Court, 29 Throgmorton Street, London, EC2N 2AT
• Telephone: +44 (0) 20 3948 1623
• Email: dataprivacy@thehive-network.com

To contact the Information Commissioner’s Office

• Postal contact: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
• Fax: 01625 524 510
• Website Complaint Submission: https://ico.org.uk/concerns/handling/